eDiscovery – Carpe Datum Lawhttps://www.carpedatumlaw.com
Legal Updates on eDiscovery, Data Privacy, and CybersecurityFri, 24 May 2019 18:29:09 +0000en-UShourly1https://wordpress.org/?v=4.9.10https://carpedatumlaw.lexblogplatform.com/wp-content/uploads/sites/190/2016/07/cropped-favicon-32x32.pngeDiscovery – Carpe Datum Lawhttps://www.carpedatumlaw.com
3232The Broad Scope of 28 U.S.C. Section 1782https://www.carpedatumlaw.com/2019/04/the-broad-scope-of-28-u-s-c-section-1782/
Wed, 10 Apr 2019 15:34:52 +0000https://www.carpedatumlaw.com/?p=2347Continue Reading...]]>Picture your client telling you they were considering starting a litigation, but that they did not yet have all the facts needed for you to prepare a pleading. Now add the wrinkle that the action would need to be forumed in a foreign country, one with discovery rules narrower than those in the United States, and then the kicker, that some of the relevant documents are held by third parties outside of the planned litigation forum. Although your initial reaction might be that your client is out of luck, 28 U.S.C. § 1782, which allows foreign litigants (or soon-to-be litigants) to obtain discovery in the United States, under U.S. discovery rules, for use in a pending or contemplated foreign proceeding, might offer some help.

Under Section 1782, a federal courts can grant an application for discovery in aid of a foreign proceeding (or planned proceeding) if the applicant: (a) has an interest in the foreign proceeding; (b) the discovery will be used in that foreign proceeding; and (c) the target of the discovery request resides in the judicial district where the request is made.[1] However, federal courts can deny the discovery request, even when those statutory factors are met, based on purely discretionary factors such as whether the target is a party to the litigation, whether the applicant is attempting to circumvent either U.S. or foreign proof gathering restrictions, and whether the requests are found “unduly burdensome.”[2] Although one might think that overworked federal courts would often use those discretionary factors to deny discovery requests in support of litigation pending in a far-flung forum, federal courts routinely grant Section 1782 applications. Two recent decisions—one granting and one denying a Section 1782 application—show just how broad discovery under Section 1782 can be.

In a recent decision,[3] the United States District Court for the District of Massachusetts granted a Section 1782 application for discovery in connection with litigation in Peru, even though it was not clear that the Peruvian court even had jurisdiction over that litigation (the question was, at the time, being reviewed by the Peruvian court). The district court reasoned that it need not wait for the Peruvian court to decide the jurisdictional question, or otherwise assess the applicants’ likelihood of success in Peru— because pursuant to the statute it was sufficient that the litigation was, again at the time, pending in Peru.[4] Although the court also held that the fact that the target of the discovery was a party to the Peruvian litigation weighed against granting the application, since the Peruvian court could, in theory, order the party to produce the requested discovery, the court granted the application anyway, finding that the other discretionary factors weighed in favor of discovery.[5]

In another recent decision, by Magistrate Judge Gabriel W. Gorenstein of the Southern District of New York,[6] the court grappled with an issue that has divided federal courts: whether Section 1782 can be used to compel the production of documents located outside the United States.[7] Magistrate Judge Gorenstein found persuasive a decision of the Eleventh Circuit Court of Appeals, which held that Section 1782 authorizes discovery to full extent allowed by the Federal Rules of Civil Procedure and those rules, in turn, authorize extraterritorial document productions.[8] Accordingly, Magistrate Judge Gorenstein held that the fact that some of the requested documents were located overseas did not bar the discovery sought, as long as the documents were within the control of a discovery target located in the U.S.—in this case, a New York-based law firm with a branch office in Russia.

Magistrate Judge Gorenstein nonetheless denied the discovery application because, among other things, issues of attorney-client privilege and whether the documents sought must be kept confidential pursuant to contract would be governed by the law of the country in which the documents were located, Russia. The court concluded that it was unclear how Russian law would apply to these documents, and that requiring disclosure could potentially force the target of the discovery application to violate Russian law. Moreover, the court worried that permitting discovery under these circumstances might encourage Russian courts to force U.S. firms to violate U.S. disclosure laws under similar circumstances. The magistrate judge also expressed concern that ruling in the applicants’ favor might discourage foreign companies from hiring the overseas offices of American firms.[9]

Magistrate Judge Gorenstein’s decision is being challenged by the Section 1782 applicants before District Judge George B. Daniels. District Judge Daniels’ decision as to whether to accept or overrule Magistrate Judge Gorenstein will be closely watched, as it could have a major impact on whether and how litigants can obtain documents via Section 1782 from U.S. entities holding relevant documents in branch offices overseas.

The facts of Strawn are gripping even in the briefest summary: Dennis Strawn was prosecuted for arson in connection with a fire that damaged his home and pickup truck, but that case against him was dismissed. Nonetheless his insurer, State Farm, denied his claim against his policy insuring the damaged property on the basis that he intentionally caused the fire. Strawn at *2. Strawn responded by suing Morris Polich & Purdy, LLP, the law firm representing State Farm, and the partner handling the case, Douglas Wood. Strawn had communicated to Wood that he refused to waive privilege as to the tax returns, but authorized his accountant to provide underlying financial records used to prepare the tax records. Nevertheless, his accountant’s office “mistakenly provided the returns along with the other financial information.” Id at 3*. Since Wood had been “expressly informed” that Strawn had not waived privilege, and rather than notifying Strawn of the error, Wood instead sent the returns to State Farm and its forensic accountant — this formed the basis upon which Strawn sued Wood for invasion of privacy. Id at 4*.

The court confirmed that Strawn had sufficiently alleged a “legally protected privacy interest.” But it also indicated that the tax privilege is “not absolute” and that it could have been overcome by an adequate showing resulting in a court order. Id at 16. The privilege should be evaluated in balancing the public policy of preventing insurance fraud against the right of confidentiality as to the tax returns, especially after evaluating whether the financial information disclosed by Strawn was sufficient to evaluate his financial condition, but faulted the unilateral decision without any court involvement. Id. The court also left open whether the alleged invasion of privacy could be proved to be “sufficiently serious in … nature, scope, and actual or potential impact to constitute an egregious breach of the social norms underlying the privacy right” after evidence was presented on the issue. Id at 17 [citing Hill v. National Collegiate Athletic Assn., 7 Cal. 4th 1, 37 (1994)] . Nonetheless, the court concluded that Strawn had not failed to state a cause of action for invasion of privacy. Id at 17.

The lessons from an eDiscovery perspective are important, as counsel may encounter tax returns in the course of document review in view of the rule articulated in State Comp. Ins. Fund v. WPS, Inc., 70 Cal.App.4th 644 (1999) and reaffirmed by Rico v. Mitsubishi Motors Corp., 42 Cal.4th 807 (2007) and McDermott Will & Emery LLP v. Superior Court, 10 Cal. App. 5th 1083 (2017). While that rule is typically construed in the context of attorney-client privilege, in its own language, the rule in Rico also applies not only to attorney-client privileged document but also where documents “otherwise clearly appear to be confidential and privileged and where it is reasonably apparent that such materials were provided or made available through inadvertence.” State Fund. at 656. The broader rule stated in State Fund is as follows:

“When a lawyer who receives materials that obviously appear to be subject to an attorney-client privilege or otherwise clearly appear to be confidential and privileged and where it is reasonably apparent that the materials were provided or made available through inadvertence, the lawyer receiving such materials should refrain from examining the materials any more than is essential to ascertain if the materials are privileged, and shall immediately notify the sender that he or she possesses material that appears to be privileged. The parties may then proceed to resolve the situation by agreement or may resort to the court for guidance with the benefit of protective orders and other judicial intervention as may be justified.”

State Comp. Ins. Fund. at 656-657. It is well established that violation of the State Fund rule can lead to the disqualification of an entire law firm from representation in a matter (Rico, 42 Cal. 4th at 810,819; McDermott, 10 Cal.App.5th at 1113-1114), but Strawn underscores the possibility of privacy torts when privileged documents such as tax returns are transmitted even outside the litigation context under California law.

Welcome to the Future: It arrived yesterday – The intersection of Technology and Legal Services

Bots, bits and bytes… Artificial Intelligence and its leading role in recent legal projects

The program will feature a panel of Seyfarth Chicago subject matter experts — with an eye toward preparing for the developments in the coming year. Our overview will be targeted at highlighting issues for the General Counsel, Chief Information Officer, Chief Human Resource Officer, and other members of their teams.

The program will consist of an engaging ninety minute presentation with speakers from each of Seyfarth Chicago’s practice groups: Benefits, Corporate, Labor & Employment, Litigation, and Real Estate, as well as an exciting presentation on the use of technology in law. Then, we will offer 30 minute break-out sessions on hot topics warranting a deeper dive that companies are facing when looking at their legal compliance needs. The break-out sessions will address Privacy/Data Security, Managing in the #metoo Environment, and Blockchain/Cryptocurrency in business.

The program is on Thursday, December 6, 2018, at 8:00 a.m. – 8:30 a.m., for breakfast and registration, 8:30 a.m. – 10:00 a.m., for the panel presentations, and 10:00 a.m. – 10:30 a.m., for the breakout sessions. Our offices are at 233 S. Wacker Drive, Suite 8000, in Chicago, IL.

The 2015 Amendments to the FRCP and their actual impacts on practitioners, including unintended consequence

How the changes to Federal Rule of Evidence 902 will change how parties and the court can streamline authentication of ESI and potentially eliminate the need to call a witness at trial

What other changes the Rules Committee is discussing that may impact eDiscovery professionals

Pilot accelerated disclosures and their impacts in Illinois and Arizona, including the Mandatory Initial Discovery Pilot Program (“MIDP”) in the Northern District of Illinois

For more information, to see the full schedule, or to register, click here.

]]>FAILURE TO ADEQUATELY ADVISE CLIENTS ON THEIR PRESERVATION OBLIGATIONS CAN BE CONSIDERED MALPRACTICEhttps://www.carpedatumlaw.com/2018/03/failure-adequately-advise-clients-preservation-obligations-can-considered-malpractice/
Fri, 02 Mar 2018 21:46:33 +0000https://www.carpedatumlaw.com/?p=2286Continue Reading...]]>By now, most litigators should know that they have an affirmative duty to advise their clients about the duty to preserve potentially relevant documents. Despite this, the United States District Court for the Southern District of New York recently denied an attorney defendant’s motion for summary judgment in part because the record was not clear as to whether the attorney defendant fulfilled its obligations with respect to the duty to preserve.

Plaintiffs allege that their defendant attorneys did not provide them with adequate guidance regarding their preservation obligations. Specifically, Plaintiffs claim that Defendants did not provide Plaintiffs with legal advice on how to respond to discovery, how to prepare their discovery responses, or advice on the “retention, storage, production of, or permissible discarding of non-responsive information.” Plaintiffs admit that they removed non relevant documents from their production. However, a few months after Plaintiffs made their production, a former employee of Industrial Quick Search submitted a declaration stating that she was instructed by Plaintiffs to remove relevant documents from Plaintiffs’ production. At a spoliation hearing, Judge Richard Owen found that Plaintiffs intentionally destroyed documents that were “likely critical to determining the scope of their copyright infringement and misappropriation of confidential information.” As a result of this finding, Judge Owen entered a default judgment against Plaintiffs.

In response to this judgement, Plaintiffs brought suit alleging that Defendants failed to issue a litigation hold and failed to supervise Plaintiffs’ preservation obligations. Defendants argue that they, as attorneys, did not have a duty to advise Plaintiffs on their duty to preserve potentially relevant documents. Defendants further argue that they issued an “oral” litigation hold and moved for summary judgement.

The Court denied Defendant’s motion for summary judgement by citing to Mosel Vitelic Corp. v. Micron Tech., Inc., 162 F. Supp. 2d 307, 311 (D. Del 2000) which stated that the “affirmative duty to preserve material extends to that party’s attorneys.” The Court further cites to Turner v. Hudson Transit Lines, Inc., 142 F.R.D. 68, 73 (S.D.N.Y. 1991) which held that the obligation to preserve relevant documents ran first to counsel, who had a duty to advise his client of the type of information potentially relevant to the lawsuit and of the necessity of preventing its destruction.”

The Court went on to specify that this “duty” on attorneys included implementing a litigation hold, overseeing compliance with the litigation hold, and monitoring their client’s compliance with the litigation hold. In light of this duty, the Court held that an attorney’s failure to fulfill this obligation falls below the ordinary and reasonable skill possessed by members of the legal bar, giving rise to malpractice risk. Applying this standard, and in the absence of a written litigation hold notice, the Court denied Defendants’ motion for summary judgement.

What Does This Mean?

Practically speaking, an attorney’s failure to advise their client on their preservation obligations can be considered legal malpractice. In order to avoid a malpractice claim, litigators should “lead the charge” with respect to preservation. They should draft a detailed litigation hold notice, work with their clients to identify recipients of the hold, specify the types of documents to be preserved, and answer any clients have regarding preservation throughout the pendency of the litigation. Simply telling a client to preserve all potentially relevant documents is not nearly enough, and this ruling reinforces the established principle that attorneys have a duty to advise their clients on appropriate preservation steps.

]]>NSA Backup Tape Spoliationhttps://www.carpedatumlaw.com/2018/01/nsa-backup-tape-spoliation/
Wed, 24 Jan 2018 18:30:59 +0000https://www.carpedatumlaw.com/?p=2284Continue Reading...]]>Eleven years into the court order levied on the NSA to preserve backup tapes containing data about the NSA surveillance efforts, it’s come to light that the NSA failed to take adequate steps to ensure the data was not deleted. Tapes containing data between 2001-2007 were deleted in 2009, 2011, and 2016, showing a systemic problem with proper data preservation. For an agency that arguably “saves everything,” this news is rather comical. The NSA’s deputy director of capabilities apologized for the failure in an October declaration, while another NSA official claimed the tapes were deleted during “housecleaning efforts aimed at making space for incoming information.” Oddly enough, there was no explanation as to why live incoming information would have been put on backup tapes, adding to the mystery of the real cause of the tape destruction. Thus far, there have been no discussions of sanctions and no requests on U.S. District Court Judge Jeffrey White to do so, at least yet. The NSA isn’t in a great position, however, since in May 2014, an NSA official assured the court that the data on the tapes was safe. The NSA now claims they are using “extraordinary” effort to try and recover the lost data. However, anyone familiar with how tape rotation works should understand it’s quite likely that the tapes were overwritten with new data, effectively making the old data permanently unreadable. The facts seem to point to a clear case of spoliation, and this time, it’s by one of the U.S. Government agencies that possessed data storage capabilities unsurpassed by any in the world.
]]>Now Available! Seyfarth Shaw’s Data Privacy & Protection in the EU-U.S. Desktop Guidehttps://www.carpedatumlaw.com/2017/12/now-available-seyfarth-shaws-data-privacy-protection-eu-u-s-desktop-guide/
Mon, 18 Dec 2017 19:32:26 +0000https://www.carpedatumlaw.com/?p=2280Continue Reading...]]>Seyfarth Shaw Offers Data Privacy & Protection in the EU-U.S. Desktop Guide and On-Demand Webinar Series

On May 25, 2018, the EU General Data Protection Regulation (“GDPR”) will impose significant new obligations on all U.S. companies that handle personal data of any EU individual. U.S. companies can be fined up to €20 million or 4% of their global annual revenue for the most egregious violations. What does the future passage of GDPR mean for your business?

Seyfarth’s eDiscovery and Information Governance (eDIG) and Global Privacy and Security (GPS) practitioners are pleased to announce the release of Data Privacy & Protection in the EU-U.S.: What Companies Need to Know Now, which describes GDPR’s unique legal structure and remedies, and includes tips and strategies in light of the future passage of the GDPR.

How to Get Your Desktop Guide:

To request the Data Privacy & Protection in the EU-U.S. Desktop Guide as a pdf or hard copy, please click the button below:

GDPR Webinar Series

Throughout August and October of 2017, Seyfarth Shaw’s attorneys provided high-level discussions on risk assessment tools and remediation strategies to help companies prepare and reduce the cost of EU GDPR compliance. Each segment is one hour long and can be accessed on-demand at Seyfarth’s Carpe Datum Law Blog and The Global Privacy Watch Blog.

For updates and insight on GDPR, we invite you to click here to subscribe to Seyfarth’s Carpe Datum Law Blog and here to subscribe to Seyfarth’s The Global Privacy Watch Blog.

]]>Spoliation and Southern Rockhttps://www.carpedatumlaw.com/2017/10/spoliation-southern-rock/
Wed, 18 Oct 2017 18:03:33 +0000http://www.carpedatumlaw.com/?p=2270Continue Reading...]]>A trial court opinion involving allegations of spoliation of text messages on a mobile phone in the Southern District of New York has gotten attention because of the application of legal preservation standards. Ronnie Van Zant, Inc. v. Pyle 2017 BL 3018, S.D.N.Y. 17 Civ. 3360 (RWS), 8/23/17) is an interesting read, not just because it involves odd characters, intrigue and drama surrounding one of the greatest Southern Rock bands of all time. It also includes some instructive information about the application of the “practical ability” test for preservation, and the uphill battle for witnesses who lose credibility in testimony about what they did and did not do in a preservation effort.

Not long after the tragic plane crash that resulted in the deaths of Lynyrd Skynyrd lead singer Ronnie Van Zandt and his co-founding band member Steven Gaines, Artimus Pyle, the former drummer, entered an agreement with the surviving heirs and other members of the band. The agreement involved promises to never perform as “Lynyrd Skynyrd,” or to generally profit from the name of the band or the tragic deaths of Van Zant or Gaines without approval of the original parties to the agreement. Their dramatically named “blood oath” agreement was more concretely memorialized in a Consent Order in 1988, following other litigation, which Pyle signed.

Over 20 years after the 1988 Consent Order, the drama that spawned the litigation began in a story that sounds like it came from a Netflix mini-series. A film director named Jared Cohn, who worked under contract for an independent record label-turned movie producer, Cleopatra Records, Inc. (“Cleopatra”) reached out to Pyle about making a movie centered around the band and Pyle’s life in it. Cohn was hired by the founder and co-owner of Cleopatra Records, Brian Perera, who is another interesting character in his own right. Pyle met and consulted with Perera on multiple occasions about ideas for a film generally depicting his life and the plane crash, which Pyle survived. In their first conversations, Pyle did not mention the 1988 Consent Order, but the Order eventually was delivered to Cleopatra. The copy of the Order was also eventually followed by a “cease and desist” letter and other correspondence from the Plaintiffs’ counsel. All the while, Cleopatra’s movie production work continued.

The description of events includes a series of attempted revisions to history by witnesses for Cleopatra and somewhat shady versions of testimony that clearly influenced the Court’s opinion about the overall reliability of both Perera and Cohn. For instance, the original title of the movie was supposed to be “Free Bird,” which would have obviously conflicted with the “blood oath” agreement. The Court mentioned in an early footnote that “Perera stated that the choice of the title ‘Free Bird’ had nothing to do with the Lynyrd Skynyrd song but, rather, was because of ‘an airplane in the sky and a bird.’” The Court quickly went on to observe that, “[s]uch an explanation is not credible.” As a result of other testimonial inconsistencies involving Perera, it is clear that the Court put very little stock in anything Perera had to say about events surrounding the film. Pulling no punches, the opinion later concluded that Perera is “an unreliable witness whose answers and demeanor evinced an attempt by the Film’s makers and producers to evade the Consent Order upon its receipt.”

After it received a “cease and desist” letter from the other parties to the Consent Order, Cleopatra changed the way it internally referred to Pyle’s role in the movie and script, but continued to work on the film. The colorful director, Jared Cohn, continued consulting with Pyle on the movie script and events in the band’s history to work into the story. While adept at a drum set, Pyle apparently did not own or know how to operate a computer, and his principle communication was text messaging. This becomes important, because most all of Cohn’s communications with Pyle occurred over text messages and telephone calls. As a result, text messages to and from Pyle during the months after Cleopatra became aware of the Consent Order were critical evidence regarding Pyle’s collaboration and the intent of the Cleopatra organization.

Undeterred by all the threatening letters it had received, Cleopatra issued a press release regarding the film’s continued development, which had been re-named “Street Survivors: The True Story of the Lynyrd Skynyrd Plane Crash.” True to his colors, Perera later testified that the fact that Lynyrd Skynyrd had a prior album titled “Street Survivors,” released just days before the plane crash was purely a coincidence, and that it was just a good title. The judge was not convinced by that explanation.

After finally coming to the conclusion that Cleopatra was ignoring its letters and demands, the other parties to the Consent Order finally filed a lawsuit against Cleopatra. After that, the revisionist history was kicked into high gear by Cleopatra personnel. Cleopatra sent a contract modification for Pyle to sign that officially changed his role. They then rushed the film to completion, including completion of the filming, sound, and other production efforts. Around the same time, the director Cohn switched cell phone providers and, despite backing up pictures and other information on the new device, failed to back up or preserve any of the critical text messages sent and received from Pyle.

The events surrounding the Cohn mobile phone becomes the focus of the inevitable spoliation charge and sanctions motion by the Plaintiffs against Cleopatra. However, there is a little more to consider, because Cohn was a non-party to the litigation. The director was a third-party contractor, but not an employee of Cleopatra. The question then became, can Cleopatra be sanctioned for the spoliation misconduct of its contract director, Cohn? In examining this question, the Court cited the widely known In re NTL Inc. Securities Litigation, 244 F.R.D. 179 (S.D.N.Y. 2007) decision that “the concept of control has been construed broadly.” The Southern District of New York uses the “practical ability” test for custody and control, which essentially means that if a party has the practical ability to obtain documents from another, regardless of legal entitlement, that is enough to find they have control for purposes of discovery and preservation. SeeIn re NASDAQ Mkt. Makers Antitrust Litigation, 169 F.R.D. 493, 530 (S.D.N.Y. 1996).

Applying the “practical ability” test, the judge concluded that “while Cohn is a non-party, his text messages were, practically speaking, under Cleopatra’s control,” because Cleopatra and Cohn had been working closely on the film. The opinion cites Golden Trade, S.r.L. v. Lee Apparel Co., 143 F.R.D 514, 525 (SDNY 1992) for the concept that a company can have legal control of documents possessed by a non-party because of a “cooperative relationship between the two.”

After determining that Cleopatra could be sanctioned for the spoliation by the director, the court proceeded through an analysis of whether sanctions are appropriate. The Court rather quickly dismissed the somewhat credible argument by Cleopatra that the Plaintiffs could have acquired the same text messages from Pyle, who presumably was the other party to the conversations. The judge said that Pyle has “made minimal appearance and has not produced any documents in this litigation,” and that “Plaintiffs have represented they sought Pyle’s messages to no avail, a credible claim…” The Court then closed out the same sentence concluding that “moreover, given the time-frame sought by the parties for this matter, this is sufficient effort.”

After then dispensing with Cleopatra’s other arguments against a sanctions award, including such creative defenses as Laches and Unclean Hands, the hammer fell. The sanctions hit Cleopatra like a fatal snake bite, with an adverse inference that resulted in a permanent injunction and other various sanctions for violations of the Consent Order, including attorney fees. As a result of the injunction, the world will never see whatever artistry and cinematic work Cohn put into the “Street Survivors” film, and all the money Cleopatra spent on the effort was gone with the wind.

While it is undeniable that the seedy misconduct by the cast of characters in the Cleopatra organization influenced the result, this opinion is still worth noting by in-house attorneys, particularly for its application of the “practical ability” test to expand the duty to preserve to include a non-party with whom the defendant had a “cooperative relationship” that related to the subject matter of the litigation. The Van Zant opinion is a reminder that a party should outline their preservation strategy as early as possible, and consider whether a non-party in possession of potentially relevant ESI may nonetheless fall under a party’s preservation obligation because they have the “practical ability” to obtain and preserve the information at issue.

]]>Richard Lutkus to Participate in Panel on “Cloud Data Collection, Processing, and Hosting” at RelativityFesthttps://www.carpedatumlaw.com/2017/10/richard-lutkus-participate-panel-cloud-data-collection-processing-hosting-relativityfest/
Wed, 18 Oct 2017 17:30:19 +0000http://www.carpedatumlaw.com/?p=2265Continue Reading...]]>Seyfarth eDiscovery Partner Richard Lutkus, along with William Lederer from Relativity and Patrick Zeller of Gilead Sciences, Inc., will host a panel discussion titled “Brave New Words: Cloud Data Collection, Processing, and Hosting” at this year’s RelativityFest on October 24, 2017.

This session will provide attendees with information about new data collection methods with tools like Heureka and Harvester, along with considerations for working with RelativityOne, data privacy, and security. Additionally, best practices surrounding the General Data Privacy Regulation (GDPR), international data transfer with EU entities, secure management of hosting (wiping cloud data) and SSD wiping technologies will be discussed.

RelativityFest is an annual conference designed to educate and connect the e-discovery community. The three-day festival in Chicago will feature panel discussions, hands-on labs, and breakout sessions to discuss best practices. For more information, or to register to attend, please visit https://relativityfest.com/.

This presentation will provide attendees with practical tips for leveraging the new Sedona International Principles to help in your compliance with stringent GDPR requirements, and in seeking immediate help under the EU-U.S. Privacy Shield.

RelativityFest is an annual conference designed to educate and connect the eDiscovery community. The three-day festival will feature panel discussions, hands-on labs, and breakout sessions to discuss best practices for eDiscovery, Information Governance, and Data Privacy. For more information, or to register to attend, please visit https://relativityfest.com/.